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UNITED STATES v. MISSISSIPPI CHEMICAL CORP.

No. 70-52.

405 U.S. 298 (1972)

UNITED STATES v. MISSISSIPPI CHEMICAL CORP. ET AL.

Supreme Court of United States.

Decided March 6, 1972.

Attorney(s) appearing for the Case

Matthew J. Zinn argued the cause for the United States. With him on the briefs were Solicitor General Griswold, Assistant Attorney General Walters, Thomas L. Stapleton, and Leonard J. Henzke, Jr.

John C. Satterfield argued the cause for respondents. With him on the brief was J. Dudley Buford.

Mac Asbill, Jr., Harold S. Cook, D. Jeff Lance, and William W. Beckett filed a brief for Agway, Inc., et al. as amici curiae urging affirmance.

MR. JUSTICE MARSHALL delivered the opinion of the Court.

Mississippi Chemical Corp. and Coastal Chemical Corp. (hereinafter taxpayers) instituted this action for a tax refund in the United States District Court for the Southern District of Mississippi. Both taxpayers are "cooperative associations" within the meaning of § 15 of the Agricultural Marketing Act, 46 Stat. 18, as amended, 12 U. S. C. § 1141j, and thus qualify for membership in one of the 12 "Banks...

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